FCA Dear CEO letter – prepare now for LIBOR changes

FCA Dear CEO letter: prepare now for the end of LIBOR

Background

• Dear CEO letter: prepare now for the end of LIBOR; published by the FCA on 27 February 2020.
• The letter is signed by Nick Miller, Head of Asset Management Supervision
• This letter is relevant to all asset management firms and, more widely, to anu financial services firms that have MIBOR-linked services and products
• The FCA has written this letter in order to set out its expcations for all firms as they prepare individually for the end of LIBOR.

Impacts

The FCA expects all firms to take all reasonable steps to ensure the end of LIBOR does not lead to markets being disrupted or harm to consumers, and to support industry initiatives to ensure a smooth transition.

Firms should be in no doubt that they have a responsibility to facilitate and contribute to an orderly end to LIBOR.   The FCA is insistent that the CEOs reflect on the points raised in this letter and act as appropriate.   LIBOR ending is a market event and the transition to alternatives is market-led.

The FCA expects firms to take proactive steps now and not to wait for instructions from clients.   Firms should not expect or base their transition plans on future regulatory relief or guidance or on legislative solutions.

This Dear CEO letter contains many sections whose titles are listed here:

• Priorities and milestones
• Products and services
• Governance and planning
• Replacing LIBOR with alternative rates in existing and new products
• Investing on clients’ behalf
• Managing conflicts of interest

If your firm has LIBOR exposures or dependencies, your transition activities should already be underway.   If LIBOR transition is not yet underway at your firm, the FCA expects you to take immediate action to develop and to begin to execute an appropriate plan.

Timeline with relevant dates to be logged on regulatory calendar

• FCA Dear CEO letter published on 27 February 2020

Next steps

For any queries or to discuss further, the FCA asks CEOs to contact its dedicated Supervision Hub on 0300 500 0597. This is the primary contact for a firm’s day-to-day interactions with the FCA.